Water UK
Water UK is the membership body for the UK water and sewerage companies.
ID: 678806016476-20
Lobbying Activity
Response to EU farm policy - Evaluation of its impact on sustainable management of the soil
27 Aug 2019
Water UK represents all major water and wastewater service providers in England, Scotland, Wales and Northern Ireland. Soil management has a substantial impact on the quality and quantity of our drinking water resources through nutrient management, pesticide use and soil erosion. Both surface water bodies and groundwater are affected by soil quality, and the performance of the Common Agricultural Policy (CAP), and any future UK regime that makes reference to it, is therefore of central concern to water companies. Additionally, sustainable management of soils should encompass the benefits of recovered and reused nutrients, carbon and water derived from waste water treatment.
The attached response outlines our view that the fitness check should establish the extent to which the CAP ensures and delivers compliance with article 7 of the Water Framework Directive, and the efficiency of the CAP in preventing the contamination of drinking water resources. We also request that the fitness check takes into account the parallel, on-going exercises by the European Commission to evaluate the Urban Waste Water Treatment Directive and the Fitness Check for the Water Framework Directive.
Read full responseResponse to European Partnership for a Circular bio-based Europe
27 Aug 2019
Water UK represents all major water and wastewater service providers in England, Scotland, Wales and Northern Ireland. Within the UK, approximately 11 billion litres of waste water are collected and treated every day. The treatment and recycling of waste water forms one of the central hubs of the circular economy.
The attached response indicates our support for the proposed European Partnership for a Circular Bio-based Europe as an effective tool to assist in overcoming barriers (such as regulatory requirements, a lack of incentives and insufficient policy co-ordination) to facilitate circular solutions.
Read full responseResponse to Revision of the Drinking Water Directive (RECAST 2017)
29 Mar 2018
Water UK support the objectives and ambition of the Directive on health protection. The proposal extends its scope beyond the fundamentals of drinking water quality having impacts wider than existing water utility areas of responsibility.
There are health benefits to be derived from addressing the parameters and their parametric values within the revision but we query whether scientific advice from the WHO has been integrated fully.
The proposal will have implications for MS, water utilities and consumers:
•stricter standard for lead is a positive public health move but will require full lead pipe replacement and addressing the use of lead in solder, brasses and fittings. The 10 year transition should be extended to min 15 yrs to enable additional policy mechanisms to be established and measures implemented;
•inclusion of additional parameters e.g. coliphages and endocrine disrupting compounds will have impacts on analytical capacity resulting in investment in assets that could become redundant after the SRA;
•increased frequency in compliance sampling will require daily monitoring that will impact resources, analytics and reporting that does not align with a risk-based approach or provide any additional health benefits.
The overarching principle in Art12 that all Annex I substances have direct health impacts is not correct. The statement that all Annex I substances constitute a health risk is an oversimplification. Where parameters without true health risks are included (e.g turbidity at taps in Part A) this results in disproportionate response and will require an increased public information requirement that may undermine consumer confidence. We propose that only parameters with true health risks are included in Annex I and those that are indicators are retained as part of Annex IV or noted as being so in an additional table.
Responsibility for Art8 is a matter of subsidiary and should rest with MS, recognising the multi-stakeholder solutions needed in improving environmental water. This can be achieved through drafting of the Art. e.g. the final part of para 5 is inappropriate as water suppliers will not have the ability to act alone to improve raw water quality.
For those new parameters introduced in Annex I we suggest that Art9 should include provisions for a period of time for water utilities to risk assess the extent to which they are present in water supplies, identify and put in place mitigation measures.
We support the Commission’s ambition to address the long-standing materials in contact with water issue. The CPR as it currently stands does not fully address the issues of protecting water quality and approval of standards. The Article should reviewed and redrafted and that there are measures put in place to manage the transition of responsibility from DWD to CPR. There are a number of specific areas in Art10 where further discussion is needed:
•responsibility for domestic and priority premises does not rest solely with the water supplier but a range of bodies, each will need to take appropriate responsibility;
•the shift from ensuring materials do not have detrimental impact on water quality to conditioning water to reduce the impacts of materials is unsustainable;
•Legionella risk assessment and monitoring should be risk and temperature based.
We support the provision of information to the public but consider that this should be a matter of subsidiarity (e.g. discoverwater.co.uk) as it is not appropriate to be legislated for in a Directive that is fundamental about public health.
There will be costs to achieve the Directive’s ambition that are not fully included in the IA – e.g. investment in new analytical methods / capacity; the increase in sampling and provision of information; developing the requirements of Art10 and also in meeting lead standards where the new standard will likely need wholesale lead pipe replacement and removing lead from brasses and fittings.
Read full responseResponse to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species
14 Dec 2017
Water UK acknowledge this proposed Regulation as a useful piece of legislation to establish commonality in the approach to assessing the information needed to determine if a species should be included on the list of Invasive Species. The proposals seem to be comprehensive and cover the main elements required to understand the potential impact of existing and emerging NNIS.
The approaches rightly acknowledges that there will be a case of a lack of knowledge in areas where species are not present and that risk assessments should be able to take account of this.
Article 2 (5) sets out the requirements for assessing certainty to account for the lack of information that may be the case when attempting to prevent the expanse of IAS to new areas. We would welcome guidance on the determination of the level of uncertainty or confidence so that preventative measures can be readily adopted.
We also fully support the inclusion of pathway risk assessments in Art 5 (1) (c), but there does seem to be some unnecessary repetition e.g. paragraph 7 repeats 4 and paragraph 5 and 6 repeat 2 and 3.
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